Law360, New York ( April 22, 2016, 11:06 AM EDT) -- As the U.S. Supreme Court has previously found in regards to electricity regulation, "Congress meant to draw a bright line, easily ascertained, between state and federal jurisdiction, making unnecessary ... case-by-case analysis."[1] Pursuant to this jurisdictional divide, states have authority over retail sales and generation facilities; the Federal Energy Regulatory Commission has authority over wholesale sales and transmission. But, with the move away from vertically-integrated utilities, the growth of regional transmission organizations/independent system operators in many parts of the country and the increased complexity of the FERC-regulated markets, the "bright line" between federal and state jurisdiction has become increasingly blurred....